SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

Bench: Us:

TDS credits. Hence, the addition of Rs. 92,069/-is sustained. 5.4. The appellant has raised several grounds 5.4. The against the addition of Unexplained Investment u/s 69B at Rs.19,54,348/- The AO made an addition of Rs. 19,54,348/- as unexplained time deposits since no source was explained during the assessment proceedings. The appellant contends that these

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

17. Coming to the issue of TDS short credit, it is submitted that after passing of the rectification order dated 03/09/2022, allowing the TDS credit, an amount of Rs. 55,920/- relates to Rail Tel Corporation of India was not addressed. We, therefore, direct the learned Assessing Officer to verify this issue and grant TDS credit in respect of Rail

OPTUM GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -5(1), HYDERABAD

In the result, both the appeals of assessee are partly allowed

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

17. Coming to the issue of TDS short credit, it is submitted that after passing of the rectification order dated 03/09/2022, allowing the TDS credit, an amount of Rs. 55,920/- relates to Rail Tel Corporation of India was not addressed. We, therefore, direct the learned Assessing Officer to verify this issue and grant TDS credit in respect of Rail

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

2): Rs.12,032/-. Also, it was\nobserved by him that the interest under section 201(1A) actually included, viz.,\n(i) short payment of tax: Rs. 17,004/-; (ii) short deduction/collection of tax: Rs.\n13,660/-; and (iii) interest under section 201(1A): Rs. 17,868/-. The CIT(A) had\nobserved that, except for the aforesaid discrepancy, the remaining amounts

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3(4), HYDERABAD

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

2): Rs.12,032/-. Also, it was observed by him that the interest under section 201(1A) actually included, viz., (i) short payment of tax: Rs. 17,004/-; (ii) short deduction/collection of tax: Rs. 13,660/-; and (iii) interest under section 201(1A): Rs. 17,868/-. The CIT(A) had observed that, except for the aforesaid discrepancy, the remaining amounts provided

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE -1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

17. Insofar as the subcontract payment of Rs. 41,90,848/-, although the assessee claims to have deducted TDS on payments wherever applicable, but on perusal of the relevant ledger accounts, we find that, although the assessee has deducted TDS on payments made to subcontractors, Shankarapally, but failed to deduct TDS on remaining unpaid amount

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

17. Insofar as the subcontract payment of Rs. 41,90,848/-, although the assessee claims to have deducted TDS on payments wherever applicable, but on perusal of the relevant ledger accounts, we find that, although the assessee has deducted TDS on payments made to subcontractors, Shankarapally, but failed to deduct TDS on remaining unpaid amount

BHUPAL INFRASTRUCTURE PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

In the result, the appeal of the assessee for A

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

17. Insofar as the subcontract payment of Rs. 41,90,848/-, although the assessee claims to have deducted TDS on payments wherever applicable, but on perusal of the relevant ledger accounts, we find that, although the assessee has deducted TDS on payments made to subcontractors, Shankarapally, but failed to deduct TDS on remaining unpaid amount

PRASANTH NANDANURU,HYDERABAD vs. ITO, (INTERNATIONAL TAXATION)-2, HYDERABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

TDS. Assessee contends that the employment is exercised where the services are rendered and at such place only the salary accrues, and, therefore, his salary had accrued in USA for the relevant period. His case is that 5(2)(b) of the Act his salary would be chargeable to tax in India only if it is accrued in India

BA CONTINUUM INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

TDS), i.e., in the violation of the provisions of section 195(1) of the Act which attracted the provisions of section 40(a)(ia) of the Act; and (ii) and though the assessee company had during the subject year carried out international transactions with its Associated Enterprises (AEs) of Rs.23,97,35,320/-, but the AO in the course

EDELWEISS BROKING LIMITED,MUMBAI vs. ACIT, CENTRAL CIRCLE-17(1), HYDERABAD

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Nuvama Wealth & Investment Limited, Acit, (Formerly Known As Circle-17(1), 527/Hyd/2022 2017-18 Edelweiss Broking Hyderabad Limited) Mumbai [Pan: Aabce9421H] Edelweiss Broking Dcit, Limited, Circle-8(1), 528/Hyd/2022 2017-18 Mumbai Hyderabad [Pan: Aabce9421H] निर्धाररती द्वधरध/Assessee By: Shri Ravikanth S. Pathak, Ar रधजस्‍व द्वधरध/Revenue By: Shri Kprr Murthy, Dr सुिवधई की तधरीख/Date Of Hearing: 03/04/2023 घोर्णध की तधरीख/Pronouncement On: 12/04/2023

section 17(2)(vi) of the Act and submitted that the discount/benefit enjoyed by the employee on receipt of shares under ESOP scheme at a concessional rate would constitute a revenue expenditure laid out or expended wholly or exclusively for the purpose of business of the assessee. According to the assessee by placing reliance on the decision of the Bangalore

DCIT CIRCLE -8(1), HYDERABAD vs. EDELWEISS BROKING LIMITED, MUMBAI

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. / Ita No. Appellant Respondent Nuvama Wealth & Investment Limited, Acit, (Formerly Known As Circle-17(1), 527/Hyd/2022 2017-18 Edelweiss Broking Hyderabad Limited) Mumbai [Pan: Aabce9421H] Edelweiss Broking Dcit, Limited, Circle-8(1), 528/Hyd/2022 2017-18 Mumbai Hyderabad [Pan: Aabce9421H] निर्धाररती द्वधरध/Assessee By: Shri Ravikanth S. Pathak, Ar रधजस्‍व द्वधरध/Revenue By: Shri Kprr Murthy, Dr सुिवधई की तधरीख/Date Of Hearing: 03/04/2023 घोर्णध की तधरीख/Pronouncement On: 12/04/2023

section 17(2)(vi) of the Act and submitted that the discount/benefit enjoyed by the employee on receipt of shares under ESOP scheme at a concessional rate would constitute a revenue expenditure laid out or expended wholly or exclusively for the purpose of business of the assessee. According to the assessee by placing reliance on the decision of the Bangalore

INCOME TAX OFFICER, WARD-16(4), HYDERABAD vs. QUARK ENTERPRISES PRIVATE LIMITED , HYDERABAD

In the result, the appeal filed by the revenue is allowed for statistical purposes

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2016-17 Ito, Ward-16(4) Vs. M/S.Quark Enterprises 1St Floor, ‘B’ Block Private Limited I.T.Towers, A.C.Guards 10Th Floor, Ramky Masab Tank Grandoise Hyderabad Ramky Towers Complex Road No.62, Gachibowli Hyderabad-500 032

17,200 5,31,76,000 Trustee, PRV Trust The Trust AAOTS1731Q 1,62,861 3,09,43,590 3,25,72,200 SR Trust The Trust AACTB3461G 5,31,513 10,09,87,470 10,63,02,600 BDS Trust TOTAL 12,62,497 23,98,74,430 25,24,99,400 3 ITA 1270/Hyd/2019 6. The AO noted

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

section 263 of the Act, under the facts and circumstances of the case. 7. The Honorable Pr. CIT ought to have appreciated the fact that, the claim of bad debts are allowable as the amount of Rs.141,66,01,735/-, is taken into account in computing the income of the Appellant of the previous years, under the facts and circumstances

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE- 1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

17. Thus, it was held that despite the amendment in section 32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain

SINGARENI COLLIERIES COMPANY LIMITED,KOTHAGUDEM vs. ACIT., CIRCLE-1, KHAMMAM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

17. Thus, it was held that despite the amendment in section 32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LTD, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

17. Thus, it was held that despite the amendment in section 32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain

DCIT., CIRCLE-13(1), HYDERABAD vs. THE SINGARENI COLLIERIES COMPANY LIMITED, KOTHAGUDEM

In the result, assessee’s appeals for the A

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

17. Thus, it was held that despite the amendment in section 32(1)(iia) of the Act, no corresponding amendment is made in section 32AC of the Act and therefore, the intention of the Legislature is clear that the benefit of section 32AC(1) is not available to a company engaged in the business of generation of power. To maintain

VODAFONE IDEA LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-14(2), HYDERABAD

In the result, the appeals and cross objections of the assessee for the Asst Years 2002-03 and 2003-04 are allowed and appeals of the revenue are dismissed

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahu

TDS) (2016) 178 ITJ 768 has held that Inter Connect Usage Charges (“IUC”) (which is similar to roaming charges) paid by assessee to foreign telecom operators was neither FTS nor royalty under the Act and DTAA. 3.5.16. Furthe, Hon’ble Delhi Tribunal following its own order in Bharti Airtel (supra) in case of Bharat Sanchar Nigam Ltd. vs. ACIT